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Chapter 2 - EXHIBIT 2B • COMPLAINT UNDER RULE 105
Jurisdiction | Colorado |
DISTRICT COURT, [county] COUNTY, STATE OF COLORADO [court's address] | ▲ COURT USE ONLY ▲ |
Plaintiff: [plaintiff's name] v. Defendants: [defendants' names]; and all unknown persons who claim any interest in the subject matter of this action | |
Attorney: [attorney's name and registration number] [firm's name] [address] Phone Number: Fax Number: Email: | Case No.: [case number] Division: [division] Courtroom: [courtroom] |
COMPLAINT UNDER RULE 105 |
Plaintiff, [plaintiff's name], by [her/his/its] attorneys, [firm's name], for [her/his/its] claim against Defendants, states as follows:
1. In this case, Plaintiff seeks to quiet title to a [number of acres]-acre parcel in [county] County, which Plaintiff has adversely possessed for over 18 years.
2. Jurisdiction is proper in this Court for this matter pursuant to C.R.S. § 13-1-124(1)(c).
3. All the real property involved in this matter is located in [county] County, Colorado, making venue proper under C.R.C.P. 98.
4. Plaintiff owns real estate known as [address of property], located in [county] County, Colorado. That property is a [number of acres]-acre tract. Adjacent to that property is the property that is the subject matter of this action ("Subject Property"). The legal description of the Subject Property is attached to this Complaint as Exhibit A.
5. Defendant [defendant's name] may claim an interest in the Subject Property pursuant to a deed recorded on [date] at Reception Number [reception number] in the real property records at the [county] County Clerk and Recorder's office or otherwise, and the claim of [defendant's name] is without foundation or right.
6. Defendant [defendant's name] may claim some interest in the Subject Property through a deed of trust recorded [date] at Reception Number [reception number] in the real estate records of the [county] County Clerk and Recorder's office or otherwise. The deed of trust has been satisfied. Defendant [defendant's name]'s claims are without foundation or right.
7. Defendant [defendant's name] may claim an interest in the Subject Property through a judgment lien recorded [date] at Reception Number [reception number] in the real estate records of the [county] County Clerk and Recorder's office or otherwise. Defendant [defendant's name]'s claims are without foundation or right.
8. Plaintiff incorporates by reference each of the...
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- Chapter 2 Mechanics of a Quiet Title Action
- Chapter 2 - CHAPTER 2 MECHANICS OF A QUIET TITLE ACTION
- Chapter 2 - § 2.1 • INTRODUCTION
- Chapter 2 - § 2.2 • INVESTIGATION
- Chapter 2 - § 2.3 • LITIGATION GUARANTEE
- Chapter 2 - § 2.4 • LEGAL DESCRIPTION
- Chapter 2 - § 2.5 • JURISDICTION AND VENUE
- Chapter 2 - § 2.6 • RIGHT TO A JURY TRIAL
- Chapter 2 - § 2.7 • DEFAULT JUDGMENT
- Chapter 2 - § 2.8 • THE DECREE
- Chapter 2 - § 2.9 • CIVIL ACCESS PILOT PROJECT
- Chapter 2 - EXHIBIT 2A • COVER SHEET — JDF 601
- Chapter 2 - EXHIBIT 2B • COMPLAINT UNDER RULE 105
- Chapter 2 - EXHIBIT 2C • SUMMONS
- Chapter 2 - EXHIBIT 2D • MOTION FOR PUBLICATION
- Chapter 2 - EXHIBIT 2I • FINAL ORDER AND DEFAULT JUDGMENT
- Chapter 2 - EXHIBIT 2J • DECREE QUIETING TITLE
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